Storage and distributed energy participation in wholesale markets

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Washington D.C., February 14, 2017—The American Public Power Association, along with the National Rural Electric Cooperative Association, filed comments with the Federal Energy Regulatory Commission on its Notice of Proposed Rulemaking on participation in organized wholesale markets by electric storage resources and distributed energy resource aggregators.

The Association generally supports FERC’s efforts to allow storage and distributed energy resources to participate in wholesale markets, but offers four principles to be used in fleshing out the final rule:

Maintain a focus on end-use customers. In removing barriers to entry for storage and distributed energy resources, FERC must move toward markets that produce just and reasonable rates for customers.

Respect state and local regulatory authority. The final rule must not undermine the ability of state and local bodies to regulate existing and future storage and/or distributed energy projects.

Protect against double-recovery and cross-subsidies. Providers of storage or distributed energy resources must not be able to doubly recover their costs — at both cost- and market-based rates — or gain access to cross-subsidies. And one class of customers should not be put in a position of subsidizing another — e.g. wholesale customers should not subsidize retail customers.

The Association’s comments also offer recommendations on specific proposals and requests for comment on FERC’s NOPR.